Assessing Officer issued on assessee a notice under section 148 seeking to reopen assessment for reasons that as per Form No. 26AS assessee’s total receipt under sections 194A, 194C and 194J was of Rs. 5.23 crores; whereas in profit and loss account it had shown total receipts at Rs. 2.61 crores which was short by 2.62 crores and this gave rise to a reason to believe that assessee did not truly and fully disclose all material facts because of which income amounting to Rs. 2.62 had escaped assessment. On writ dismissing the petition the Court held that  notice under section 148 had been issued after conducting an investigation and after recording a reason to believe that assessee did not truly and fully disclose all material facts, impugned notice did not suffer from any illegality.  (AY.  2013-14)